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matelot1965  
#1 Posted : 04 July 2022 21:24:39(UTC)
Rank: Forum user
matelot1965

Hi All,

`I have just had a DSEAR assessment and it has been noted that our vehicle charging points are within 15 metres of propane tanks  and a transformer which the risc authority  documents RC59 does not recommend

https://www.riscauthority.co.uk/public-resources/documents/resource/rc59-fire-safety-when-charging-electric-vehicles-401

My question is what do we do about it without either moving or physically separating by enclosure charging points, gas tanks or transformers none of which are really practical to do. Is there a solution out there to modify charging points e.g fit with spark arrestors.

`I now bet they wished they had involved the H+S dept in the installation 

antbruce001  
#2 Posted : 05 July 2022 09:40:32(UTC)
Rank: Forum user
antbruce001

Hi,

This guidance is new to me, and it appears to contridict the general approach to DSEAR requirements in a number of areas.

With regards to the specific issue you have detailed; the 15m seperation you mention seems excessive. I can't see why such a distance is required. Any hydrogen created during the charging process is not going spread 15m horizonally - no matter how much is produced as it is signficantly lighter than air and will naturally rise. Also, with a suitably bunded tank, I can't see how any Zone created around a bunded fuel tanks would extend this distance. Simply, the application of DSEAR/HAC principles would not require such a seperation. The only thing I can think of, as to the reasoning for this distance is the risk of a lithium fire may pose to the tank - in particular a risk of heating the tank to create a BLEVE, but again I find this quite a far fetched scenerio. I think this is overly conservative on all counts, but guidance is guidance. I will have to think about how to apply this going forward.

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matelot1965 on 07/07/2022(UTC)
peter gotch  
#3 Posted : 05 July 2022 10:00:56(UTC)
Rank: Super forum user
peter gotch

Morning matelot1965

So, presume the bit in the guidance you are referring to is 

"5.6.5 Where it is not practicable to provide this degree of physical separation of a vehicle charging area within a building as indicated in paragraph 5.6.3 (and also outside the premises), no charging should be undertaken within 10m of any combustible materials: be they waste materials, stock or combustible elements of the structure. Similarly, no charging should be undertaken within 15m of hazardous installations such as transformers, flammable liquid stores and liquefied petroleum gas tanks."

The document was published in 2021 and might not have been out when your charging points were installed, but in any case, is guidance rather than a prescriptive requirement of DSEAR or other legislation and will be inherently erring on the conservative side - as example, it doesn't set different separation distances depending on the scale of "hazardous installations" and doesn't distinguish between an LPG tank that has an intumescent coating +++ against one that does not have such additional protection.

Suggest your starting point is to establish what authoritative (or semi-authoritative) guidance was in place when the charging points were being procured and identify what was written in to the specification for the installation of those charging points.

So, if the specification said words to the effect of "comply in full with .RISCA RC59", then may be you go back to the installer and tell them to comply with Contract - but that is somewhat subject to whether a Contract Administrator has signed off the Contract as being successfully completed to specification.

Then you look at who the Contract Administrator was - if within the organisation, somewhat stuffed, but if you have bought in that service, then may be an action against the CA.

Part of this might depend on the handover documentation provided with the charging points. Does this warrant that all is fine and dandy?

Now assuming that reverting to issues surrounding the procurement is not going to work, you then need to decide what to do, if anything, to comply with the relevant legislation. That probably means getting in a specialist to do a detailed DSEAR assessment to explain why you can depart from the details of the RISCA guidance or do whatever to mitigate aspects where the installation departs from that guidance.

.....and that will have to look at multiple variables - e.g. for the LPG tank(s) - how many, what capacity, how loaded (and, if ever, unloaded), methods of coupling, actual distance from the charging points (and other potential sources of ignition) - so, if say 14m from the nearest charging point it's a fairly minor departure from the RISCA guidance and might fall within relevant guidance from the UK LPG Association and World equivalent (I think that some of the UKLPGA guidance is a free download) + other variables that could be fed in to a Quantified Risk Assessment which in turn might be subject to qualitative risk assessment to address issues that are beyond the scope of the software that would inform a QRA - topography, prevailing winds etc etc.

Ignoring the transformer for the purposes of this message, suppose you have a 1 tonne LPG tank, it might easily be cheaper to relocate the LPG tank or one or two of the charging points than to pay for a specialist DSEAR assessment to justify departurss from the RISCA guidance - but you could probably make a judgement on the extent of "non-compliance" with the RISCA guidance to niform how you proceed and may be the decision makers might come to a "do nothing" position - and possibly that is the right conclusion for the site and its constraints. 

Almost everything in this decision making is about achieving what is reasonably practicable or "ALARP" - and it is time to brush off "R2P2" and start looking at the bits on what the Individual Risk of Death ("IR") is and whether that sits in the "Broadly Acceptable" or some other range.

Good luck, Peter

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matelot1965 on 07/07/2022(UTC)
Ian Bell2  
#4 Posted : 05 July 2022 17:52:59(UTC)
Rank: Super forum user
Ian Bell2

WHat size are the propane tanks? 

The HSE website gives guidance on separation distances from other buildings / activities etc - can't say unlees the tank size is known/

The HAC distance from propane / LPG tanks is typically 2m or so around the PRV and any valves/regulators in the LPG compound. 

The HAC around battery charging if the batteries are of the type to release hydrogen will be no more than 1m. See HSE leaflet INDG 39 (If I remember correctly). In the open air the hydrogen will quickly disperse due to its density/buoyancy

The 15m distance is sounding far too conservative- even possibly impractical

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matelot1965 on 07/07/2022(UTC)
Ian Bell2  
#5 Posted : 05 July 2022 18:02:33(UTC)
Rank: Super forum user
Ian Bell2

I've just had a quick scan read of the RICS guidance. Its seems to be nonsense. It aries widely from both of the common standards used for hazardous area classification. That is IP/EI Part 15 Hazardous area classification for flammable liquids and BSEN 60079-10-2 Explosive atmospheres.

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A Kurdziel on 06/07/2022(UTC), matelot1965 on 07/07/2022(UTC)
Ian Bell2  
#6 Posted : 06 July 2022 11:05:47(UTC)
Rank: Super forum user
Ian Bell2

Slight correction to my previous post the HAC BS is 60079-1 Not -2. Part 2 is for dusts.

And to answer the originl posters query - what should they do.  Ignore the RC59 guidance and complete your DSEAR hazardous area assessment using BS50079-10-1. You will find the HAC distances are no where near to 15m.

I would also assume your LPG tanks are installed following the LPG Association guidance/HSE guidance.

I would doubt you have any additional work to complete

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matelot1965 on 07/07/2022(UTC)
John Elder  
#7 Posted : 06 July 2022 14:56:12(UTC)
Rank: Forum user
John Elder

Ignor RC59 its for insurance underwritters to get out of a claim and isnt worth the paper it is written on.

Apply the hazardous Classification Zones and Distances as per Code of practice 1 Buld LPG Storage at fixed installations 2017 Section 8.2 unless a specific DSEAR Risk assessment Justifies a lower value.

The reference in Ians lase message was meant to be BSEN 60079-10-1 and not BSEN 50079-10-1 its just a Typo.

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matelot1965 on 07/07/2022(UTC)
matelot1965  
#8 Posted : 07 July 2022 21:05:18(UTC)
Rank: Forum user
matelot1965

Thanks all for the input really helpful. I got some research to do on all of that But as I poster said 15m does not seem practical and I was struggling to find a practical solution 

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